ML25022A032
| ML25022A032 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 01/22/2025 |
| From: | Bradley Davis NRC/RGN-II/DFRSS |
| To: | Dailey R Nuclear Fuel Services |
| References | |
| EPID I-2024-004-0048 IR 2024004 | |
| Download: ML25022A032 (23) | |
Text
Ronald Dailey President Nuclear Fuel Services, INC.
P.O. Box 337 MS 123 Erwin, TN 37650-0337
SUBJECT:
NUCLEAR FUEL SERVICES (NFS) - INTEGRATED INSPECTION REPORT 07000143/2024004
Dear Ronald Dailey:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from October 1, 2024, to December 31, 2024, for the Nuclear Fuel Services (NFS) facility. On January 14, 2025, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Bradley J. Davis, Chief Fuels Oversight Branch 1 Division of Fuels, Radiological Safety, and Security Docket No. 07000143 License No. SNM-124
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV January 22, 2025 Signed by Davis, Bradley on 01/22/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/ DFRSS RII/ DFRSS RII/ DFRSS NAME N. Peterka L. Harris B. Davis DATE 1/22/25 1/22/25 1/22/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000143 License Number:
SNM-124 Report Number:
07000143/2024004 Enterprise Identifier:
I-2024-004-0048 Licensee:
Nuclear Fuel Services, INC.
Facility:
Nuclear Fuel Services (NFS)
Location:
Erwin, TN Inspection Dates:
October 01, 2024 to December 31, 2024 Inspectors:
L. Harris, Senior Resident Inspector C. Oelstrom, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facility Project Inspector A. Ponko, Senior Construction Project Inspector T. Sippel, Sr. Fuel Facility Project Inspector Approved By:
Bradley J. Davis, Chief Fuels Oversight Branch 1 Division of Fuels, Radiological Safety, and Security
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Nuclear Fuel Services (NFS), in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Section Status WER 07000143/2024-001 CAAS Inaudibility (EN57131) 88015 Closed
3 PLANT STATUS The following facility process areas were operating during the inspection period: Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF), which includes the Uranium-Oxide (U-Oxide), solvent extraction and the down blending lines. Normal support services and departments were operational during the inspection period.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program to verify compliance with selected portions of Title 10 of the U.S. Code of Federal Regulations (10 CFR) 70, including 70.24, 70.50, 70.61, 70.62; Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (NCSEs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.1, 5.5.2, 5.5.3, and 5.5.4.
Specifically, the inspectors interviewed licensee staff and reviewed the following NCSEs:
54T-08-0010, "Nuclear Criticality Safety Evaluation BLEU Production Facility Downblending," Rev. 08, including review of the licensee's what-if analysis, normal, credible abnormal, and non-credible accident sequences and upset conditions (e.g., the evaluation of the transfer piping from building 330 to 440) 54X-04-0019, "Nuclear Criticality Safety Evaluation for 105/302/303 Laboratory of the Production Fuel Facility," Rev. 1, including review of the licensee's what-if analysis, normal conditions and credible accident sequences and upset conditions (e.g., spacing upsets) 54X-13-0006, "Nuclear Criticality Safety Evaluation 6-inch Rocket Storage in 105 Laboratory," Rev. 0, including review of the licensee's what-if analysis, normal conditions and credible accident sequences and upset conditions (e.g.,
storage of overloaded containers)
4 54X-14-0002, "Control Flowdown and Field Verification for the 6-inch Rocket Storage in 105 Laboratory," Rev. 0, which was reviewed because it contained documentation of how the items relied on for safety (IROFS) established in 54X-13-0006 were verified to be implemented 54X-24-0008, "Nuclear Criticality Safety Analysis for Nominal 6-Inch Diameter Borosilicate Glass Columns," Rev. 2, including review of the licensee's what-if analysis, normal conditions and credible accident sequences and upset conditions (e.g., improper analyses, etc.)
54X-09-0001, "Nuclear Criticality Safety Evaluation for the HEPA filtered Balance Enclosure (IAC760)," Rev. 0, including review of the licensee's what-if analysis, normal conditions and credible accident sequences and upset conditions (e.g., excessive mass accumulation)
Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative controls from the licensees ISA Summary to verify proper implementation through a review of process and system descriptions, plant walk-downs, and operator interviews to verify compliance with 10 CFR 70 and sections 5.3.5 and 5.3.7of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls and management measures associated with the NCSEs listed above, including:
administrative mass control IROFS LAB-1 in the 105 Laboratory, and associated NCS Posting administrative concentration control IROFS LAB-36 in the 105 Laboratory, and associated NCS Postings administrative spacing control IROFS LAB-6 in the 105 Laboratory, and associated NCS Posting administrative piece count control IROFS 6IR-1 in the 105 Laboratory, and associated NCS Postings administrative mass control IROFS 6IR-2 in the 105 Laboratory, and associated NCS Postings engineered controls (e.g., BDB-10 and RTD-4), including review of safety related equipment (SRE) test records the inspectors observed surveillance of IROFS 333-USVXTR for the Building 333 Solvent Extraction System the inspectors conducted walkdowns of fuel operations in the 300 Building complex, the 105 Laboratory, the Blended Low Enriched Uranium (BLEU) area, and the LEU transfer line
5 Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2, 5.3.4, and 5.5.3.
Specifically, the inspectors performed the following activities:
reviewed the NCS audit reports (e.g., NCS-2024-010) for 2024, and interviewed the NCS engineers about the scheduling, planning, and tracking of NCS audits and walkdown, as well as the tracking and trending of audit findings observed a licensee NCS engineer conduct an audit of the 900 Area and reviewed recent audit reports completed since May 2024 (e.g., NCS-2024-013) interviewed three lab technicians concerning criticality hazards and control methods, including the controls applied before transferring solutions to unfavorable geometries Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including 2.3.5.1, 5.2, 5.3.3, 5.3.5, and 5.3.6. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
reviewed the qualification records of two in-training NCS Engineers and interviewed them about the qualification process reviewed the qualification records of two NCS Engineers who are working on the Senior NCS Engineer qualification the most recent revision to licensee procedure NFS-HS-A-58 Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and problem identification, resolution and correction system (PIRCS) entries to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2, 5.3.9, 5.4 and 11.6. Additionally, the inspectors followed-up on a written event report (WER) related to a CAAS outage in May. Specifically, the inspectors reviewed documents, and interviewed licensee staff concerning the following:
reviewed selected NCS and CAAS related PIRCS entries (e.g., 100968, 101040, 101164, 101181, 101461, 103734) and associated documents reviewed recent NCS evacuation drill records and performance for 2023 and 2024, and interviewed licensee NCS engineers about emergency response walked down in-line monitors, including two newly installed isolation valves associated with one of the monitors, and interviewed licensee NCS staff regarding in-line monitor alarms and PIRCS entries (e.g., 101982)
6 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.
Plant Tours (IP Section 03.01)
The inspectors performed weekly tours of plant operating areas housing SNM to verify that licensed activities were conducted safely and in compliance with the license and 10 CFR 70, Domestic Licensing of Special Nuclear Material.
Status Meetings (IP Section 03.02)
The inspectors attended and reviewed the results of licensee meetings on a routine basis to identify the status of plant activities and properly focus NRC inspection resources on activities with the higher safety significance:
Plan of the Day Meetings Safety and Security Review Council Problem Resolution Meetings Scheduled meetings with licensing, security, and facility management Record and Log Reviews (IP Section 03.03)
The inspectors reviewed selected records and logs to ensure they were developed, maintained, and reported, as required by applicable license and regulatory requirements.
The records selected for review are listed in the "Documents Reviewed" section of this inspection report.
Identification and Resolution of Problems (IP Section 03.05)
The inspectors reviewed selected issues to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track, and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements. The issues selected for review are listed in the "Documents Reviewed" section of this inspection report as PIRCS.
7 Event Review (IP Section 03.06)
The inspectors reviewed the weather event listed below to determine if the event warranted the use of formal event review criteria and to evaluate the licensees response was in accordance with 10 CFR Parts 70, 73,and 20:
The inspectors reviewed the following licensee actions associated with a community flooding event due to Hurricane Helene that occurred September 27, 2024, to determine whether they were performed in accordance with implementing procedures and license requirements.
o Activation of the Emergency Response Organization o
Use of guidance directed in associated site procedures o
Notifications to local and state agencies o
Suspension of operations and shutdown status, stop movement of licensed material, and isolation of flammable gas supplies o
Accounting of site personnel o
Delivery of sufficient diesel deliveries to keep generators and UPS systems operational o
Continuation of security systems and plant-wide announcement systems o
Flood water and survey sampling o
Commercial power restoration and checking of systems before they were reenergized o
Repair/replacement of damaged environmental sampling equipment o
Confirmation of the ability to discharge treated liquid effluents o
Return-to-work briefings for site personnel prior to restart of operational areas Audits (IP Section 03.07)
The inspectors reviewed a sample of internal and/or external audits performed since the previous inspection to determine whether they have been performed in accordance with 10 CFR 70.22(h)(1), implementing procedures, and license requirements:
2024 Third Quarter NCS Report Health Physics Audits/Inspections, Third Quarter ALARA Report, Third Quarter Industrial Safety, Third Quarter Radiation Work Permit (RWP) (IP Section 03.09)
The inspectors reviewed and observed the RWPs (also known as safety work permits or SWPs) listed below to determine whether they contained the information required in Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and licensee implementing procedures:
SWP 18905, 303-200 SWP 18922, 302-900
8 88135.04 - Resident Inspection Program Operational Safety The inspectors reviewed the material condition and as-found configuration of selected site structures, systems, and components (SSCs); reviewed corresponding documentation, and interviewed licensee personnel to verify compliance with 10 CFR Part 70 and the license application. The inspectors also verified whether the selected SSCs were available and reliable to adequately protect plant workers and the public during normal, off normal, and accident conditions.
Operations Safety Walkdown (IP Section 03.01)
The inspectors performed walk-downs and evaluated the safety controls/IROFS listed below associated with the building 302 Areas E-J processing areas.
FMF-20 FAF-17 FMF-22 FMF-23 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of selected fire protection SSCs to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and the National Fire Protection Association (NFPA) standard 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as applicable.
Also, the inspectors evaluated fire brigade training and performance to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and NFPA 600, "Standard on Industrial Fire Brigades."
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and reviewed the documents listed below for two fire areas of the facility:
306 East and West o
Controls associated fire walls, dampers, and doors o
Pull stations o
Detection devices Fire controls in or near areas E-J in building 302 o
Fire-1 o
Fire-2 o
Cease Fire system Fire Brigade Drill Performance Sample (IP Section 03.02)
The inspectors evaluated the fire brigade response as described below:
Response, command, and control during a false alarm evaluation on December 12, 2024
9 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with Chapter 11, Management Measures, of the license application; and test procedures or work orders (WOs) to confirm functional capability of selected IROFS and safety controls following maintenance.
Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the post-maintenance tests listed below. The inspectors either observed the tests directly or reviewed test results.
NJCGSFLOFSVGS07, Area 800 Utility, Work Order 312873 N302WOGNT0E02, Work Orders WR314412 and 314412A 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance or calibration tests to ensure they were available and reliable to perform their function when needed; to verify compliance with Chapter 11, Management Measures, of the license application, and the requirements of 10 CFR 70.61 and 70.62; and to verify the IROFS maintained their operational readiness consistent with the ISA Summary.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the three surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.
N302VENDRAIN01A N307VENDRAIN029 N303VENDRAIN022 N304VENDRAIN034 N306VENDRAIN004 N302FLAMDETECTR, Area 600 FACILITY SUPPORT 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and Chapter 11, Management Measures of the license application. The inspectors review also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the license application, and that modifications involving new processes met the requirements in 10 CFR 70.64.
10 Permanent Plant Modifications The inspectors observed construction activities associated with the Utility Building 389 slab on grade for the U-Metal project. The inspectors observed the reinforcing steel installed in the slab on grade to determine if the sizes, spacing, location, and layout of the bars were consistent with the applicable design drawings and American Concrete Institute, Building Code Requirements for Structural Concrete (ACI 318-14). The inspectors also reviewed the concrete mix design for the slab on grade to determine if the mix met the requirements of ACI 318-14 and the structural general notes. The inspectors reviewed material test reports and a product data sheet to determine if the reinforcing steel and shrinkage reducing admixture, respectively, met the requirements of ACI 318-14, the structural general notes, and the applicable American Society of Testing and Materials (ASTM) standards.
The inspectors also observed concrete placement activities associated with the Utility Building 389 slab on grade. The inspectors reviewed concrete batch plant tickets to verify if the approved mix was batched and placed in the foundations. The inspectors observed field sampling and testing of fresh concrete to verify if the temperature, slump, and air content of the material delivered to the site conformed to the specified requirements and activities were completed in accordance with the applicable ASTM standards. The inspectors also observed placement activities to determine if the concrete deposited in the slab on grade was properly consolidated by suitable means to minimize the potential for voids or honeycombing.
The inspectors also reviewed two nonconformance reports to verify if nonconforming items or conditions were appropriately identified, evaluated, and documented.
Specifically, the inspectors reviewed the reports to determine if nonconforming items or conditions dispositioned use-as-is or repair were reviewed, evaluated, and approved by the design authority and the associated documentation included adequate technical justification for the acceptability of the as-built condition.
Sample Selection (IP Section 02.01)
The inspectors reviewed licensing documents, changes the licensee determined did not require pre-NRC approval under 10 CFR 70.72, and changes that affected the ISA summary to select changes/modifications to review. To assess whether the licensee conducted evaluations according to their established configuration management system, the inspectors selected the following plant modifications, identified as Engineering Change Requests (ECRs) to review:
ECR 2024-0711, "PCN 20.D to SOP 401-04 303 IROFS Skid Alarm Response" ECR 2024-0944, "Off Gas Piping Epoxy" ECR 2023-0942, "Add Four Rosemount Differential Pressure Gages on the IROFS Skid System" ECR 2023-0723, "Add Malfunction Relay Wiring to Mangetrol Level Switch on BPF Blend Tank" ECR 2023-0655, "Add Shutoff Valves Downstream of 105-GL-NI100 to Allow an Isolation Point for Nitrogen Supply to the ROTAP Enclosure"
11 ECR 2024-0064, " Add Check Valves to Outlet Side of Reagent Pumps -
A200" ECR 2023-0993, "Addition of Flowmeter FI-S640A" ECR 2019-1580-23, "Move NA Valve" Facility Change/Modification Process (IP Section 02.02)
The inspectors reviewed the selected modifications listed above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the inspections activities listed below:
reviewed the following procedures to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10 CFR 70.72(a):
o NFS-CM-004-01, "Preparation of Change Control Package Documentation," Rev. 1 o
NFS-CM-004, "NFS Change Control Process," Rev. 24 o
NFS-ENG-010, "Acceptance Testing Program," Rev. 9 o
ENG-EPS-A-005, "Engineering Practices and Standards - Baseline Design Criteria for IROFS," Rev. 3 o
NFS-ENG-021, "Engineering Design Review Process," Rev. 5 o
NFS-GH-43, "Safety-Related Equipment Control Program," Rev. 34 o
NFS-GH-901, "Configuration Management Program," Rev. 24 o
NFS-HS-A-67, "Documenting the Safety & Regulatory Review of Facility Changes," Rev. 17 o
NFS-HS-A-79, "Identification and Control of Items Relied on for Safety (IROFS) Procedure," Rev. 16 interviewed licensee staff and reviewed the above configuration management packages to verify the licensees evaluation of changes provided valid technical bases to determine whether an amendment to the license was required based on the criteria in 10 CFR 70.72(c).
performed walked downs of the following ECR's:
o ECR 2024-0064, " Add Check Valves to Outlet Side of Reagent Pumps - A200" o
ECR 2023-0993, "Addition of Flowmeter FI-S640A" o
ECR 2019-1580-23, "Move NA Valve" reviewed facility documentation associated with the selected changes to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) or the timeframe outlined in the license reviewed 2023 configuration management system records to verify the licensee submitted a summary with facility changes and revised ISA Summary pages to the NRC in accordance with 10 CFR 70.72(d)
12 Management Measures (IP Section 02.03)
For the selected modifications, the inspectors reviewed the management measures established for affected IROFS to verify the management measures ensured the IROFS were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license. Specifically, the inspectors conducted the inspection activities listed below:
interviewed licensee staff and reviewed change management procedures to verify the licensee implemented the aspects described in configuration management system procedures and the license application.
interviewed licensee staff and reviewed affected procedures to verify the licensee followed the procedure control process in accordance with the license.
reviewed post-modification testing procedures and test results to verify they ensured adequate implementation of the design and functionality of the safety systems.
reviewed maintenance and surveillance records of the above modifications to verify the licensee established periodic maintenance and surveillance testing in accordance with the license.
interviewed licensee staff and reviewed training records to verify the staff involved in facility changes were qualified in accordance with the license and plant procedures.
interviewed licensee staff and reviewed training records to verify the licensee conducted training on plant modifications in accordance with the license application and plant procedures.
reviewed the condition reports listed in the Documentation Section to determine whether the licensee identified configuration management, post-modification testing, and/or plant modification issues and corrected the condition in accordance with approved corrective action program procedures and the license.
reviewed configuration management system audits and assessments, listed in the Documentation Section, and interviewed licensee staff to verify the scope and frequency of audits were being conducted in accordance with the license application and facility procedures.
License Application Changes (IP Section 02.04)
For the selected modifications, the inspectors interviewed licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements. Specifically, the inspectors conducted the inspection activities listed below:
reviewed the licensees procedure used to determine whether NRC pre-approval of license application changes is required to verify the licensee correctly evaluated license application changes.
13 New Processes at Existing Facilities (IP Section 02.05)
The licensee had not implemented any new facility processes at the time of the inspection.
Therefore, the inspectors review did not include evaluations of whether the licensee addressed the baseline design criteria and defense-in-depth as stipulated in 10 CFR 70.64.
Records Retention (IP Section 02.06)
The inspectors reviewed a sample of plant documents impacted by the selected modifications to verify the licensee maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:
operating procedures: SOP 416, "Programmable Logic Controller (PLC)
Configuration Control Program," Rev. 8 training records: Engineering Design Authority (EDA) qualifications and training records and Nuclear Criticality Safety review qualifications and qualification card system drawings: (see Documents Reviewed Section of this report)
INSPECTION RESULTS Minor Violation 88015 CAAS Inaudibility (EN57131)
Minor Violation: In Event Notice (EN) 57131, NFS notified the NRC that the CAAS had been found inoperable. Specifically, on May 17 at 1930, the newer redundant CIDAS speaker system had been disabled to conduct an annual drill. At 2101, the CAAS alarm was sounded over the legacy speaker, and it was discovered that the alarm was inaudible in Building 303.
Immediate compensatory actions were taken to shutdown processes, limit personnel, and provide temporary communication in the area. The redundant speaker system was restored to service at 2137 and later tested to confirm CAAS audibility in Building 303 at 2249.
Then on May 18, the legacy system speakers in Building 303 were restored by replacing the speakers and a portion of wiring. However, the alarm system capability to identify faults for this speaker zone was not restored by replacing the components. Daily functional tests of the legacy speakers in Building 303 were implemented until further wire replacements restored the system's ability to identify faults in the speakers.
The inspectors reviewed, 21G-24-0113, "30-Day Speaker Event (NRC Event 57131),"
dated June 10, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession Number: ML24191A261) that described the above event and corrective actions. The inspectors noted that the CAAS was not able to meet the requirements of 10 CFR 70.24 for about 2.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before the licensee discovered the event and implemented compensatory measures. There were no actual safety consequences as a result of this event.
The potential consequence is that evacuation of Building 303 would have been delayed if a criticality would have occurred while the CAAS was inoperable. The inspectors also noted that Building 303 is a major process area in which large quantities of SNM are handled and stored.
14 The inspectors interviewed licensee staff about the causes of the event, the compensatory actions and the corrective actions. As well as past tests that showed the system was working the week before. The inspectors reviewed PIRCS entries 101164 and 101181 and their associated documents; and Work Request (WR) 309890, which was used to repair the CAAS by replacing speakers and wiring.
10 CFR 70.24(a) requires, in part, that the licensee "maintain in each area in which such licensed special nuclear material is handled, used, or stored, a monitoring system... which will energize clearly audible alarm signals if accidental criticality occurs."
Contrary to this requirement, on May 17, from about 1930 to 2137, the licensee failed to maintain in Building 303, where licensed special nuclear material is handled and stored, an alarm system that was capable of generating clearly audible alarm signals if accidental criticality was to occur. Specifically, the old CAAS alarm wiring had degraded such that the alarm single in Building 303 was not audible when the newer CIDAS alarms were disabled for the drill.
Screening: The inspectors determined the violation was minor. Because it aligns with 'minor' case of minor/more-than-minor example 2.k from Inspection Manual Chapter 0616 Appendix B due to the very short duration of the violation.
Enforcement: This failure to comply with 10 CFR 70.24 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy. This closes WER 0700143/2024-001-00, "CAAS Inaudibility (EN57131)."
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On January 14, 2025, the inspectors presented the integrated inspection results to Ronald Dailey and other members of the licensee staff.
On December 12, 2024, the inspectors presented the nuclear criticality safety and permanent plant modifications inspection results to Frank Kerns and other members of the licensee staff.
15 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date SA-00131 Setpoint Analysis for RTD-004 09/28/2015 Calculations SA-00228 Setpoint Analysis for FLW-004 09/11/2024 SRE Calibration N306MONITR4WD01 Completed 07/10/2024 Calibration Records SRE Calibration N333MONITR4RAFF Completed 05/02/2024 100968, 101040, 101164, 101181, 101461, 103734 NCS-related PIRCS entries Various Corrective Action Documents 101982 In-line monitor alarms 333-F0603-D Raffinate Treatment and Disposal P&ID 07/22/2024 Drawings 333-I3464-B1 BLEU Preparation Facility Loop Sheet In Line Radiation Detectors RE-4B11 Recirculation on Tank 4C01 54T-08-0010 Nuclear Criticality Safety Evaluation BLEU Preparation Facility Downblending Rev. 08 54X-00-0019 Nuclear Criticality Safety Analysis for 105/302/303 Laboratory of the Production Fuel Facility Rev. 1 54X-04-0025 Risk Index and IROFS Summary for 105 Laboratory Rev. 0 54X-08-0011 Addendum 3 to Revision 1 of the Nuclear Criticality Safety Analysis for 105/302/303 Laboratory of the Production Fuel Facility use of a Piece Count to Control the Mass in the Sample Selection Stations Rev. 1 54X-09-0001 Nuclear Criticality Safety Evaluation for the HEPA Filtered Balance Enclosure IAC760)(U)
Rev. 0 54X-13-0006 Nuclear Criticality Safety Evaluation 6-inch Rocket Storage in 105 Laboratory Rev. 0 Engineering Evaluations 54X-24-0008 Nuclear Criticality Safety Analysis for Nominal 6-Inch Diameter Borosilicate Glass Columns Rev. 2 SRE Test N306MONITR4WD01 Completed 04/04/2024 2025 Criticality Audit Schedule 88015 Miscellaneous 2023 and 2024 Criticality Evacuation Drills Various
16 Inspection Procedure Type Designation Description or Title Revision or Date SRE Test N333MONITR4RAFF Completed 04/07/2024 SRE Test N333MONITRE4B11 Completed 06/13/2024 54X-14-0002 Control Flowdown and Field Verification for the 6-inch Rocket Storage in 105 Laboratory Rev. 0 NFS-HS-A-16 Safety Audits, Assessments, and Inspections Rev. 16 NFS-HS-A-58 Nuclear Criticality Safety Evaluations (NCSEs)
Rev. 15, 09/25/2024 NFS-HS-CL 07 Nuclear Criticality Safety 105/302/303 Laboratory: Sample Storage Rockets Rev. 10, 06/21/2024 NFS-HS-CL 10 Nuclear Criticality Safety 105/302/303 Laboratory: 11-Liter Waste Solution Cylinders Rev. 4 NFS-HS-CL 15 Nuclear Criticality Safety 105/302/303 Laboratory: Sample Transportation Rev. 7 NFS-Q-202 Inspection and Analysis of Six-Inch Glass Rev. 12 Procedures SOP 409, Section 16 LEU Downblending Operations Rev. 35 NCS-2024-10 Eighth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for Area 900 SNM Storage Racks 05/23/2024 NCS-2024-11 Twelfth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for Area C of the Uranium Recovery Facility 05/22/2024 NCS-2024-12 2023 Nuclear Criticality Safety (NCS) Audit of the Training Program 05/22/2024 NCS-2024-13 Eighth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for ENLOS-7901 in Area 900 of the Production Fuel Facility 05/22/2024 NCS-2024-14 Twelfth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for he Tube Cleaning Room of the Fuel Manufacturing Facility 06/04/2024 Self-Assessments NCS-2024-15 Twelfth Nuclear Criticality Safety Audit of the SNM Processing Operations for Area 800 of the Production Fuel 06/03/2024
17 Inspection Procedure Type Designation Description or Title Revision or Date Facility NCS-2024-18 Twelfth Nuclear Criticality Safety Audit of the 300 Complex Process and 105 Laboratory Exhaust Ventilation Systems 07/02/2024 NCS-2024-27 Fifth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for 6 Inch Rocket Storage in the 105 Laboratory 11/07/2024 Work Orders WR 309890 CAAS Speaker/wire replacement 05/18/2024 Calculations DESCALC-UMETAL-S001 Building 389 Building Foundation & CMU Walls Rev. 2 100863 Audit; Procedures and Administrative Controls 04/23/2024 49636 Revise NFS-GH-901 06/17/2024 Corrective Action Documents 93825 External Audit/ Assessment/ Review; Personnel 09/18/2023 105-F0054-D STAB-H17 & STAB-102 PI&D 03/02/2024 17400-R10 Slab on Grade Rebar Replacement Plan, Sheet 5 of 5 Rev. 1 17400-R6 Slab on Grade Rebar Replacement Plan, Sheet 1 of 5 Rev. 1 17400-R7 Slab on Grade Rebar Replacement Plan, Sheet 2 of 5 Rev. 1 17400-R8 Slab on Grade Rebar Replacement Plan, Sheet 3 of 5 Rev. 1 302-F1159-D Vacuum Pump IROFS System PI&D 04/21/2023 303-E1105-D(B1) 300-500 Modernization Building 303 I/O Assignment PLC Panel S51 Remote Rack 1 12/08/2021 303-F0121-D Area 200 PI&D Sheet 1 02/08/2021 303-F0151-D Area 200 Modernization PI&D Sheet 5 of 10 09/09/2022 333-E3412-D BLEU Preparation Facility Digital Input Wiring Diagram Down Blending PLC Panel 333-CNTPNL-000 03/04/2024 389-A1002-D 389 Building Architectural General Notes Original Issue 389-A1003-D 389 Building First Floor Plan Original Issue 389-A1009-D 389 Building Building Sections Original Issue 389-A1010-D 389 Building Interior Wall Elevations Original Issue 88070 Drawings 389-A1011-D 389 Building Interior Wall Elevations Original Issue
18 Inspection Procedure Type Designation Description or Title Revision or Date 389-A1020-D 389 Building Structural General Notes (Sheet 1)
Original Issue 389-A1021-D 389 Building Structural General Notes (Sheet 2)
Original Issue 389-A1022-D 389 Building Foundation Plan Original Issue 389-A1023-D 389 Building Foundation Sections & Details Original Issue 389-A1024-D 389 Building Foundation Sections & Details Original Issue 389-A1025-D 389 Building Masonry Wall Details Original Issue 2019-1580-23 Move NA Valve 09/27/2023 2023-0655 Add Shutoff Valve DS CE 105-GL-NI100 to Allow and Isolation Point for Nitrogen Supply to the ROTAP Enclosure 05/31/2023 2023-0723 Add Malfunction Relay Wiring to Magnetrol Level Switch (333-LSH-4C01B) 06/23/2023 2023-0723 Add Malfunction Relay Wiring to Mangnetrol Level Switch on BPF Blend Tank 06/23/2023 2023-0942 Add Four Rosemount Differential Pressure Gages on the IROFS Skid System 09/29/2023 2023-0993 Addition of Flowmeter FI-5640A 09/30/2023 2023-1309 PE Instrumentation and Update to SOP 409, Section 6, Revision 3.B 01/02/2024 2024-0064 Add Check Valves to Outlet Side of Reagent Pumps - A200 01/15/2024 2024-0711 PCN 20.D tp SOP 401-04 303 IROFS Skid Alarm Response 06/16/2024 2024-0944 Off Gas Piping Epoxy 07/23/2024 2024-1238 LOA WWTF-24-004, Compensatory Measures for IROFS WWT-19, WWT-20, and WWT-21 for Processing High COD Solution 09/26/2024 Engineering Changes 2024-1362 LOA WWTF-24-007 10/31/2024 Engineering Evaluations SAREV -
20240266 BLDG 303, Area 400-500 Miscellaneous Individuals Qualified for ENG-Advisory - EDA 12/10/2024
19 Inspection Procedure Type Designation Description or Title Revision or Date Qualifier Maintenance - LOA WWTF 24-004 Compensatory Measures for IROFS WWT-19, WWT-20, and WWT-21 9/20/2024 Individuals Qualified on LOA-24-004 9/20/2024 Qualified Maintenance - LOA WWTF 007 Compensatory Measures for IROFS WWT-19, WWT - 20, &
WWT-21 10/29/2024 Sika Corporation Product Data Sheet, SikaControl-75, Shrinkage Reducing Admixture Summers Taylor, Inc., Concrete Mix #S50M5F20T, 5000 psi Interior Concrete with No Air and Shrinkage Reducing Admixture Qualifications - Advisory - EDA-Advisory Engineer Engineering Design Authority and List Job Requirements 12/10/2024 FM-NFS-A-67-01 Safety & Regulatory Review Routing Form Rev. 7 NFS-MGT-03-005 Configuration Management Policy Rev. 5 Nonconformance Report (UPQI-F-04)
B389 Anchor Rod Embedment Nonconformance Report (UPQI-F-04)
B389 Incorrect Slab-on-Grade Rebar Bends OPR-TB-SEP23-07 CM Software Changes 09/28/2023 Heat 54202398/02 Certified Mill Test Report, Gerdau, ASTM A615, #4, Grade 60 Heat 54202997/02 Certified Mill Test Report, Gerdau, ASTM A615, #5, Grade 60 Heat 6048211 Certified Mill Test Report, CMC Steel, ASTM A615, #4, Grade 60 NDE Reports Heat 7041532 Certified Mill Test Report, CMC Steel, ASTM A615, #5, Grade 60 ENG-EPS-A-005 Engineering Practices and Standards - Baseline Design Criteria for IROFS Rev. 3 Procedures NFS-CM-004 NFS Change Control Process Rev. 24
20 Inspection Procedure Type Designation Description or Title Revision or Date NFS-CM-004-01 Preparation of Change Control Package Documentation Rev. 1 NFS-ENG-010 Acceptance Testing Program Rev. 9 NFS-ENG-021 Engineering Design Review Process Rev. 5 NFS-GH-43 Safety-Related Equipment Control Program Rev. 34 NFS-GH-901 Configuration Management Program Rev. 24 NFS-HS-A-67 Documenting the Safety & Regulatory Review of Facility Changes Rev. 17 NFS-HS-A-79 Identification and Control of Items Relied on for Safety (IROFS) Procedure Rev. 16 SOP 416 Programmable Logic Controller (PLC) Configuration Control Program Rev. 8 Triennial CM Program Assessment Required by LIC-SNM-124 Ch. 11.5.2 09/10/2024 Semi-annual Project Review Involving Connection of New Equipment to Existing Configuration Management Controlled Systems 09/12/2024 Naval Nuclear Quality Performance Evaluation (QPE) 10/13/2023 QA-24-03 Configuration Management Audit - Quality Assurance Audit 03/14/2024 Self-Assessments QA-24-06 Procedural Management Measure Audit 04/23/2024 104145 PIRCS Corrective Action Document 104148 PIRCS Corrective Action Document 104188 PIRCS Corrective Action Document 104200 PIRCS Corrective Action Document 104218 PIRCS Corrective Action Document 104236 PIRCS Corrective Action Document Corrective Action Documents 104245 PIRCS Corrective Action Document NFS-HS-E-03 Emergency Response Organization Rev. 040 SOP 401-06A-303 AREA 600 PSL Rev. 005 C 88135.02 Procedures SOP-409-SEC 8 U-Oxide Rev. 076